ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassess the income in respect of these years. A combined reading of both the provisions indicates that where a pending assessment has abated, the total income will comprise of the normal income on the basis of returned income plus the income escaping assessment on the basis of seized material found in the course of search. Where the assessment has reached

SHRI CHHAGANBHAI MULJIBHAI PATOLIYA,JETPUR vs. THE ITO WARD-1 (2) (3) RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.477/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) Chhaganbhai Muljibhai Patoliya, Vs The Ito Ward 1(2)(3), Radhe Park, Shreeji School, Aayakar Bhavan, Race Course, . Amarnagar Road, Rajkot (Gujarat) - 360001 Jetpur (Gujarat) - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ddrpp2365A (Appellant) (Respondent)

reassessment proceedings u/s. 147 of the I.T. Act was initiated by issuing a notice u/s.148 to the assessee on 28.03.2019 after recording the reasons for reopening and with the prior approval of the Pr. Commissioner of Income Tax - I, Rajkot by invoking the provisions of Capital Gain including section 50C of the I.T. Act for the property transactions made

SHRI MANOJ B. MANSUKHANI,,RAJKOT-GUJARAT vs. THE PR. COMMISSIONER OF INCOME TAX-1, , RAJKOT

In the result, the appeal of the assessee is allowed

184/- against the proprietor’s capital of " 142,83,93,492/-. Hence the assessee has made investment in unquoted shares of " 5, 96,90,880/- from interest-bearing funds. Further, in view of CBDT Circular number 05/2014 dated 11-02-2014 clarifying that under Rule 8D I.T.A No. 50/Rjt/2022 A.Y. 2017-18 Page No 3 Shri Manoj B. Mansukhani